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Industry’s Emergency Preparedness Focus

Industry’s Emergency Preparedness Focus. National Radiological Emergency Preparedness Conference April 13, 2005. NEI Issue Review Alan Nelson, Chief Emergency Preparedness Nuclear Energy Institute Reevaluation of Emergency Preparedness David E. Leaver, Polestar Applied Technology, Inc. .

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Industry’s Emergency Preparedness Focus

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  1. Industry’s Emergency Preparedness Focus National Radiological Emergency Preparedness Conference April 13, 2005

  2. NEI Issue Review • Alan Nelson, Chief Emergency Preparedness Nuclear Energy Institute • Reevaluation of Emergency Preparedness • David E. Leaver, Polestar Applied Technology, Inc.

  3. NEI Issue Review • NEI Mission/Essential Issue • EP Post 9/11 Actions • EP/Security Integration • Bioterrorism Preparedness and Response • NEI Emergency Preparedness Forum

  4. Nuclear Energy Institute • The Washington, D.C. Policy organization of the nuclear power industry • To create favorable U.S. Energy policy for the continued safe use of nuclear energy

  5. Nuclear Energy InstituteEmergency PreparednessEssential Issue • Emergency preparedness involves technical or operational issues of significance that can have political and financial impacts on all, or most of the industry

  6. Nuclear Energy InstituteOutreach • NEI Public Web Page • http://www.nei.org • Essential Issue Fact Sheets • Issue Policy Briefs

  7. EP/Security Integration • NEI EP Working Group • NEI Security Working Group • NEI EP/Security Task Force • Nuclear Sector Coordinating Council • NRC EP ICM Implementation • EP/Security Table Top Drills

  8. EP/Security Integration • Transition Force on Force Exercises • EP Drill Guidelines • Lessons Learned • NEI Force on Force Forum (Sept ’04) • Federal Interactions - Calvert Cliffs, Indian Point • Validate National Response Plan

  9. EP/Security Integration • Full Scale Integrated Exercises - Indian Point, Diablo Canyon • Industry Lessons Learned (NEI EP Forum, NREP Conference) • NEI letter to Administrative Points of Contact 08/03/04 • Ensure security program modifications are integrated into emergency response and operations

  10. Current EP Security Related Initiatives – Post 9/11 Actions • Additional threat based emergency classification levels (EALs) • New onsite and offsite protective actions based on external events • Expedited notification methods • Training and performance evaluation involving threat event focus

  11. Proposed Post 9/11 Actions • Revises Emergency Classification Level (ECL) definitions to include a terror based perspective • Adds HOSTILE ACTION definition • Adds four new Initiation Conditions (ICs) and Emergency Action Levels (EALs) • One Unusual Event (UE) EAL • Two Alert EALs • One Site Area Emergency (SAE) EAL

  12. Proposed Post 9/11Implementation Guidance • EAL Guidance • Provides specific guidance for NEI 99-01, NUMARC/NESP-007, and NUREG-0654 users • Includes entire security related EAL set that revised Emergency Plans should contain • Changes made in accordance with this guidance are not a decrease in effectiveness and may be performed under 10 CFR 50.54(q) without prior NRC approval • Should coordinate changes with State and Local Offsite Response Organizations (OROs)

  13. Threat Based Training Drills and Exercises • Ensure that emergency, operations and security response organizations are well integrated • Formulate NEI EP Security Task Force • Frame a process to develop guidance for the conduct of evaluated threat based exercises within the 6 year cycle

  14. Phase 1 – Develop Materials and Conduct Pilot Tabletops • Initial draft of guidance documents • Industry guideline • Extent of play • Objectives and demonstration criteria • Scenario abstracts • Conduct pilot tabletops • Region IV SONGS (June 22) • Region III Duane Arnold (Nov) • Region II (TBD) • Region I Seabrook (Oct)

  15. Phase 1 – Drill Scheme

  16. Phase 2 – Test Baseline Drills • Revise guideline based on Phase 1 results (Jan ’06) • Conduct 2 site drills (Feb-Apr ’06) • Diablo Canyon • TBD

  17. Phase 3 – Test Baseline Drills • Revise guideline based on Phase 2 results (May ’06) • Seek NRC endorsement and perform a Joint Industry/NRC Workshop (June ’06) • Utilities conduct baseline Security Event Drills (Beginning July ’06)

  18. Phase 4 – Implement New Exercise Program • Once all sites have completed initial drill incorporate into 6 year exercise plan

  19. Bioterrorism Preparedness and Response - Potassium Iodide 10-20 miles • Public Law 107-188 Section 127 • Make KI available for stockpiling and distribution to the public out to 20 miles • HHS Guidelines – Distribute Potassium Iodide 10-20 miles • Distributed for State comment

  20. Bioterrorism Preparedness and Response • NAS recognized that sound science coupled together with sound public policy did not support widespread KI distribution. The committee stated that distribution of KI be the responsibility of the State to determine what methods, distances and populations are appropriate for their unique circumstances. • This effort should be dismissed in accordance with Section 127 (f) Applicability and funds dedicated to this effort be directed to more urgent bioterrorism uses.

  21. Bioterrorism Preparedness and Response • 25 states commented on the guidelines • Significant concerns voiced • Could lead to defacto expansion of the EPZ • Results in an unfunded mandate • Potential loss of public confidence • No scientific basis to justify KI expanded distribution

  22. Bioterrorism Preparedness and Response • Options • Federal Register notice for public comments • Use and application of subsection (f) “stop applying if the President finds better alternatives to KI” • Legal interpretations of section (f)

  23. Bioterrorism Preparedness and Response • Health and Human Services should include the following questions in the FR notice: • Did NAS satisfy the request to determine the most effective and safe way to distribute and administer KI on a mass scale?

  24. Bioterrorism Preparedness and Response • Does the draft Federal Guidelines for requesting Potassium Iodide (KI) from the Strategic National Stockpile meet the intent of the public law? • The Public Law Provisions for Applicability (f), “stop applying if the President finds better alternatives to KI,” do you believe there are better alternatives to met the intent of the law?

  25. Bioterrorism Preparedness and Response • Has the Public Law provisions been met and call it victory? • The President has made KI available • States have made a determination • Ingestion pathway protective actions are in place

  26. Emergency Preparedness and Communications Forum San Diego, California • June 13- 14 Emergency Preparedness and Communications Forum • June 15 - Emergency Preparedness RUG • June 15-17, Emergency Preparedness Training Course

  27. Emergency Preparedness and Communications Forum San Diego, California • You will hear updates on: • NEI, INPO updates • Emerging issues • Regulatory activities, NRC, DHS/FEMA • EP/security exercise initiatives and lessons learned • Real-events lessons learned • Inspection insights • Outreach and public confidence • Communication issues and new challenges

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